The District generates and reviews quarterly reports to monitor its State and local maintenance of effort expenditure requirements; however, the District mistakenly included American Recovery and Reinvestment Act (ARRA) funds in its calculations, which should be excluded to demonstrate compliance. Consequently, for the 2010-11 fiscal year, District records indicated that State and local expenditures, in total and average per capita, decreased from the 2009-10 fiscal year to the 2010-11 fiscal year. In addition, District records did not evidence that the District met a qualified exemption from the maintenance of effort requirement. Consequently, the deficiency in maintenance of effort from State and local funds totaling $514,035 represents questioned costs subject to disallowance by the grantor. Without effective procedures to monitor applicable maintenance of effort requirements, the risk increases that State and local funds will not be properly allocated and expended for special education services.